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Archive for the International Taxation & Reporting Category

IRS Issues Additional Guidance on Transition Tax on Foreign Earnings

April 2, 2018 The Treasury Department and the Internal Revenue Service today provided additional guidance (Notice 2018-26) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax Cuts and Jobs Act enacted on Dec. 22, 2017. The Treasury…

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TAX CUTS AND JOBS ACT (H.R. 1) – Businesses, Tax-Exempt Orgs & International

BUSINESSES Corporate Taxes H.R. 1 calls for a 21-percent corporate tax rate beginning in 2018. The new law makes the new rate permanent. The maximum corporate tax rate currently tops out at 35 percent. Although the current 2017 maximum corporate tax rate is 35 percent, many corporations…

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TAX CUTS AND JOBS ACT (H.R. 1) – Individuals

The Tax Cuts and Jobs Act (H.R. 1) has been approved by Congress and signed by President Trump. After a last-minute procedural glitch that required the Senate to vote first on the final bill, the most sweeping change to the U.S. tax code in decades cleared the…

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IRS CI Division Chief Unveils International Tax Enforcement Group

The IRS Criminal Investigation Division (IRS-CI) is putting together a new international tax enforcement group, according to IRS-CI Chief Don Fort. This information was revealed publicly to reporters for the first time during an August 2 conference call. The new initiative is expected to be fully operational…

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IRS Highlights Form 1042-S Filing, Common Errors, Amended Forms and Extensions

The IRS has reminded withholding agents of their responsibilities, some reporting changes and some common errors. The IRS also described filing requirements for non-U.S. citizens in certain circumstances. The due date for Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, is March 15. To request…

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Bill Introduced to Increase Foreign Investment in U.S. Real Estate

On Thursday, April 30th, two senior members of the House Ways and Means Committee, Kevin Brady, R-Tex., and Joe Crowley, D-N.Y., reintroduced legislation, the Real Estate Investment and Jobs Bill of 2015 (HR 2128), that would remove a 1980s era tax provision that discourages foreign investment in U.S.…

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Securities Industry and Financial Markets Association (SIFMA) Criticizes FATCA

The entire burden for implementing the Foreign Account Tax Compliance Act (FATCA) falls on U.S. and foreign financial services firms, according to the Securities Industry and Financial Markets Association (SIFMA). In addition, a former acting IRS commissioner who helped oversee the rollout of the anti-tax evasion law…

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Six Key Business Tax Issues To Watch For in 2015

As companies assess the political landscape for 2015 they will also find an evolving economic outlook, and a heightened focus on tax transparency that could add “incredible uncertainty” to the tax outlook in 2015, says KPMG. Therefore, business executives will need to keep a close eye on…

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Interest Paid by Foreign Disregarded Entity Was U.S. Source Income

The IRS Chief Counsel determined that interest paid by a foreign disregarded entity of a U.S. domestic corporation to a foreign corporation was U.S. source income under Code Sec. 861(a)(1) and, therefore, subject to withholding under Code Sec. 1442. The foreign corporation payee was a controlled foreign…

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Action Needed to Ensure Tax Compliace with FIRPTA

According to new audit report from the Treasury Inspector General for Tax Administration (TIGTA), current IRS procedures are insufficient to ensure that all foreign seller real estate transactions subject to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) are in fact compliant with FIRPTA.…

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